Privacy Impact Assessment for the USCIS ELIS: Form I-90 DHS/USCIS/PIA-056 November 13, 2014 Contact Point Donald Hawkins Privacy Officer United States Citizenship and Immigration Services (202) 272-8000 Reviewing Official Karen L. Neuman Chief Privacy Officer Department of Homeland Security (202) 343-1717
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Privacy Impact Assessment
for the
USCIS ELIS: Form I-90
DHS/USCIS/PIA-056
November 13, 2014
Contact Point
Donald Hawkins
Privacy Officer
United States Citizenship and Immigration Services
(202) 272-8000
Reviewing Official
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security
(202) 343-1717
Privacy Impact Assessment
USCIS ELIS: Form I-90
Page 1
Abstract
The Department of Homeland Security (DHS) United States Citizenship and Immigration
Services (USCIS) operates the USCIS Electronic Immigration System that processes the USCIS
Form I-90 (“ELIS: Form I-90”). ELIS: Form I-90 is the second iteration of the IT system
developed by USCIS called “ELIS.” ELIS: Form I-90 allows USCIS applicants to electronically
file, and USCIS to electronically adjudicate, Form I-90, Application for Replacement of
Permanent Resident Card for a limited introduction period. USCIS conducted this PIA to
evaluate the privacy impacts of converting a paper-based process to an electronic system. As
ELIS: Form I-90 expands to additional form types, USCIS will update this PIA.
Overview
USCIS is the component within DHS that oversees lawful visits and immigration to the
United States. This includes receiving, adjudicating, and granting a wide variety of immigration
benefits. Historically, USCIS has relied on manual paper processes to perform this function.
ELIS: Form I-90 is a new information technology (IT) system with an external online interface
that electronically conducts the entire immigration benefit transaction, from external applicant
intake to internal USCIS processing, adjudication, and response.
ELIS: Form I-90 is a new USCIS system; however USCIS also operates a previously-
developed system called “ELIS.” USCIS plans for ELIS: Form I-90 to eventually replace the
previously-developed ELIS system. USCIS is developing and publicly rolling out ELIS: Form I-
90 in a series of releases that correspond to specific immigration form types. The two systems
will run in parallel for the first ELIS: Form I-90 release.
This PIA covers the first release of ELIS: Form I-90; it does not cover the previously-
developed ELIS.1 This PIA documents the seventy-two-hour “Limited Introduction” release of
the system, after which the capability will be disabled. This Limited Introduction allows USCIS
a controlled set of data to carefully monitor the system’s operations in the live environment and
ensure the system is working as designed before a permanent roll-out.
The Limited Introduction allows certain Lawful Permanent Residents (LPR) to request
replacement Permanent Resident Cards (PRC) commonly known as “Green Cards.” During the
1 For detailed descriptions and privacy risk assessments of the original ELIS system, please see the following PIAs:
DHS/USCIS/PIA-041 – ELIS-1 Temporary Accounts and Draft Benefit Requests (May 26, 2012), available at,
Limited Introduction, applicants who visit the USCIS webpage to learn how to request a
replacement PRC will have the option to apply online through ELIS: Form I-90, in addition to
the existing option of downloading the equivalent paper form. Seventy-two hours after USCIS
enables ELIS: Form I-90, the webpage will revert back to its original version and the ELIS:
Form I-90 option will no longer be available. Applicants who have created accounts during that
window will continue to be able to access their accounts at the direct ELIS: Form I-90 URL, but
that URL will not accept new signups. Internal USCIS users, such as the personnel adjudicating
the applications, will then use the system to adjudicate the request according to existing
adjudication protocols. Once those introduction applications are fully processed, USCIS expects
to resolve any issues identified during the introduction and then release the system permanently.
USCIS will update this PIA when USCIS launches the permanent iteration of ELIS: Form I-90
and for any additional ELIS form updates.
Background
ELIS: Form I-90 is the second iteration of the IT system developed by USCIS and called
“ELIS.” This PIA covers the new system. The previously-published USCIS Electronic
Immigration System PIAs, referenced below, cover the previously-developed ELIS system.
USCIS plans to consolidate the two systems into one in the near future and will update this
ELIS: Form I-90 PIA accordingly. USCIS will also retire the PIAs that cover the previously-
developed ELIS system when that system is decommissioned.
The reason that USCIS has retained the name “ELIS” for both systems is to preserve
applicant recognition of ELIS as the online immigration benefits system and provide the most
seamless applicant experience. For this Limited Introduction, ELIS: Form I-90 runs in parallel
with the previously-developed (and still operational) ELIS system. The two systems are
completely separate, including separate login accounts for applicants and employees and a
different user interface. However, the new system does follow the same general purpose and data
collection process as the previously-developed system.
USCIS does not anticipate that running the two systems at the same time will confuse or
otherwise adversely impact applicants. Each system accepts different benefit types,2 which limits
the number of applicants who have reason to access both systems. Also, USCIS is initially
limiting the number of applicants who can access the new system via this introduction release to
allow for pre-testing and identification of any functionality or capability that may require
modification before making the system permanent. USCIS customer service is equipped to
handle any issues that arise.
2 The previously-developed USCIS ELIS contains the electronic Form I-539, Application to Extend Stay/Change
Status as a Nonimmigrant; electronic Form I-526, Immigrant Petition by Alien Entrepreneur; a Document Library
(for EB-5 petitions associated with Regional Centers); and the ability to pay the $165 USCIS Immigrant Fee.
Privacy Impact Assessment
USCIS ELIS: Form I-90
Page 3
System Description
Applicant Request Process
If an applicant chooses to file a Form I-90 electronically during the seventy-two hour
introduction, he or she will be directed to ELIS: Form I-90. The applicant will create an
electronic account, which requires providing an email address. The email address serves as the
applicant’s ELIS: Form I-90 username and the applicant will also create a password. To establish
two-factor authentication, the applicant must then choose to provide a mobile phone number to
receive a short message service (SMS) access PIN, or the applicant may choose to provide
answers to security questions that he or she will answer upon subsequent logins in addition to
username and password. The security questions are “fill-in-the-blank” questions that to which
the applicant provides the answer at account set-up. USCIS provides the applicant with a drop-
down menu of standard questions, and the applicant chooses which ones to use as his or her
security questions.3 USCIS will not use the answers to these questions for purposes other than
assisting with password resets (e.g., the answers would not be available to adjudicators for an
immigration benefit purpose or fraud investigators in the event of a fraud investigation.)
Once the login account is set up, the applicant can begin drafting his or her application
for a replacement PRC. The user interface looks very similar to the existing paper Form I-90,
although questions dynamically expand or become disabled as the applicant completes the
request, thereby requiring the applicant to respond only to applicable questions. The electronic
questions are identical to the questions asked in the paper Form I-90, so there is parity between
the electronic and paper processes. The electronic format also provides some advantages to the
user, such as a validation of mailing address against U.S. Postal Service (USPS) known
addresses.
The user has the option to use a corrected address, validated by the USPS Address
Standardization Web Tool,4 to prevent address formatting confusion or typographical errors.
When the applicant enters his or her mailing address into his or her electronic Form I-90, ELIS:
Form I-90 bounces the address entered against addresses recognized by USPS. If the USPS tool
does not recognize the address, ELIS: Form I-90 will display a pop-up window informing the
applicant that the address was not found and suggest an alternative recognized address that the
USPS tool suggests as a close match. If there is no close match, the USPS tool provides an
alternative address for ELIS: Form I-90 to suggest. The applicant is then given the option to
accept the suggested address or ignore the suggestion and use the address he or she originally
typed. At any time that the application is in draft, the applicant may go back and re-enter the
address, which will trigger a re-validation by the USPS service.
3 For example, the applicant may choose, What is your favorite type of candy? as a security question.
4 Via this service, USPS does not ingest or store the address provided by ELIS: Form I-90.
Privacy Impact Assessment
USCIS ELIS: Form I-90
Page 4
Based on the answers the applicant provides in his or her application, ELIS: Form I-90
prompts the applicant to upload evidence. For example, if the applicant requests a replacement
PRC because of a legal name change through marriage, the system will prompt the applicant to
upload evidence of the legal name change such as a marriage certificate. Applicants upload
evidence by scanning documents and attaching those scanned copies to the ELIS: Form I-90
application.
Applicants who create their accounts and begin their applications during the Limited
Introduction period can save their applications as draft and return to them later by logging in
directly to ELIS: Form I-90. If they are still drafting the application after 30 days, they will
receive a warning that their draft is expiring, and after the warning period, USCIS will consider
the draft abandoned and will delete the draft from the system. That draft data is only accessible
to the applicant during that draft period and if deleted will never be reviewed by USCIS
personnel. (There are very limited exceptions, such as if an applicant needs a USCIS Customer
Service Representative to assist in resetting a password while the data is in draft.)
Once the applicant enters all necessary information and uploads the evidence, ELIS:
Form I-90 requires the applicant to electronically sign (e-sign) the application and pay the
applicable fee. The applicant can review the information he or she is about to submit, and then e-
signs by entering their ELIS: Form I-90 password. Payment is made using the U.S. Department
of Treasury’s Pay.Gov service.5 ELIS: Form I-90 does not collect the fee directly. Rather, the
Pay.Gov interface is imbedded within the ELIS: Form I-90 user interface, and Pay.Gov collects
payment information—either credit card, debit card, or personal check. Pay.Gov validates the
payment information and sends the applicant back to ELIS: Form I-90. At this point, ELIS: Form
I-90 confirms to the applicant that he or she successfully submitted the application and that
USCIS will mail a receipt notice to the applicant’s physical address and make it available
electronically via the applicant’s ELIS: Form I-90 account.
Automated System Checks
The first data element the ELIS: Form I-90 validates on the applicant’s electronic Form I-
90 is the applicant’s Alien Registration Number (A-number). ELIS: Form I-90 validates the A-
number to ensure the case is processed with the correct A-Number. All applicants requesting
replacement PRCs should have records in USCIS legacy systems, either because USCIS
previously granted them LPR status or the applicant entered the United States on an immigrant
visa. These applicants also all have A-numbers, which is the primary account number USCIS
assigns to each immigrant. ELIS: Form I-90 runs an automated comparison of the A-number
claimed by the applicant against the USCIS legacy Central Index System (CIS)6 to verify that (1)
5 U.S. Department of Treasury Financial Management Services Pay.Gov Privacy Impact Assessment 2.0 (July 1,
2011), available at, http://fms.treas.gov/pia/paygov_pia%20.pdf. 6 DHS/USCIS/PIA-009, Central Index System PIA (June 22, 2007), available at,
Privacy Impact Assessment
USCIS ELIS: Form I-90
Page 5
the A-number exists and is valid, and (2) matches the name and identifying information claimed
by the applicant. If the system cannot automatically verify this information, ELIS: Form I-90
moves the applicant’s request into an electronic work queue where it will be researched and
resolved by a USCIS employee or contractor before proceeding.
During the A-Number validation, USCIS also runs a criminal and national security
background check against the U.S. Custom and Border Protection’s (CBP) TECS system.7 If that
check results in the identification of potential criminal or national security issues, USCIS makes
a referral to the USCIS Fraud Detection and National Security (FDNS) directorate for separate
investigation. This referral does not impact the request for replacement PRC except in special
circumstances. After the A-Number is validated, ELIS: Form I-90 interfaces with the National
Application Scheduling System (NASS)8 to schedule an appointment for the applicant to appear
at an Application Support Center (ASC), where USCIS is able to verify identity in-person by
collecting biometrics. NASS generates an appointment notice that USCIS mails to the physical
address provided by the applicant. ELIS: Form I-90 holds the applicant’s request for replacement
PRC pending completion of the ASC appointment.
Adjudicating the Application
The applicant’s request for replacement PRC advances once the legacy USCIS Benefits
Biometric Support System (BBSS)9 sends an indication that the applicant has submitted his or
her biometrics at the ASC.
ELIS: Form I-90 automatically places the application in an adjudicator work queue after
A-number validation, completion of the TECS background check, and return of the background
and security check results through the BBSS have occurred. The USCIS adjudicator evaluates all
data—the information submitted by the applicant along with the results of the background and
security checks—according to existing standard operating procedures (SOP) that apply to the
legacy paper process.
The internal ELIS: Form I-90 interface assists the adjudicator in deciding whether to
grant the replacement PRC by allowing the adjudicator to request additional evidence
electronically, and to electronically review criminal and national security background check
results to resolve any issues. To assist the adjudicator in verifying the information that the
applicant submitted, ELIS: Form I-90 displays the applicant’s basic biographical data (e.g.,
name, date of birth, place of birth, gender) from CIS alongside data submitted to ELIS: Form I-
http://www.dhs.gov/xlibrary/assets/privacy/privacy_pia_uscis_cis.pdf. 7 DHS/CBP/PIA-009, TECS System: CBP Primary and Secondary Processing PIA (December 22, 2010), available
at, http://www.dhs.gov/xlibrary/assets/privacy/privacy_pia_cbp_tecs.pdf. 8 Privacy Impact Assessment pending publication to http://www.dhs.gov/uscis-pias-and-sorns.
9 DHS/USCIS/PIA-033 Immigration Benefit Background Check System PIA (November 5, 2010) available at,